UK regulators have intervened in the packaging recycling evidence market after stricter accreditation and enforcement rules cut the availability of Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs).
Regulatory Position Statements were issued on 9 October, following concerns that some producers and compliance schemes might otherwise struggle to show they had met their 2026 recycling obligations.
Reduced thresholds for three materials
Under the position statements, regulators will not normally take enforcement action where businesses reach at least:
- 83% of the statutory plastic recycling obligation;
- 92% of the statutory steel recycling obligation;
- 90% of the statutory wood recycling obligation.
Full compliance is still required for every other packaging material.
What drove the shortfall
The Foodservice Packaging Association (FPA) said the intervention followed a series of changes made during 2026 to strengthen the integrity of the PRN/PERN system. These included tighter accreditation requirements for reprocessors and exporters, a new fit-and-proper-person test, more enforcement activity, and revised export rules under which PERNs can only be issued once packaging waste reaches the overseas reprocessing facility.
Defra says the measures have improved transparency and helped tackle fraud and error, but have also reduced the number of accredited reprocessors and exporters and lengthened the time taken to issue PERNs, constraining the supply of recycling evidence.
Obligations unchanged, records required
The Environment Agency's Regulatory Position Statement 383 makes clear that statutory recycling obligations have not been amended. Businesses that satisfy the conditions of the RPS will not normally face enforcement action for missing the original targets in the three affected materials, but Certificates of Compliance will still record non-compliance where statutory obligations have not been met.
Companies relying on the RPS must keep supporting records for five years, meet their full obligations for other packaging materials and continue to comply with all other applicable requirements. The intervention applies only to the 2026 compliance year.
Pressure builds ahead of 2027
Defra has described the circumstances as exceptional and committed to reviewing recycling targets for 2027, taking account of factors including the introduction of deposit return schemes (DRS) and the delayed mandatory kerbside collection of plastic film in England.
The FPA said the DRS impact will be particularly significant. Under current arrangements, in-scope PET plastic bottles and aluminium and steel drinks cans collected through DRS will no longer generate PRNs or PERNs from October 2027. That removes valuable, relatively high-quality material from the existing evidence market, even though it will continue to be recycled through the new scheme.
The delayed introduction of mandatory kerbside collections for plastic film in England, now scheduled for April 2030, adds a further consideration when assessing how much material is likely to be available for recycling and for PRN generation. Longer-term reform of the PRN/PERN system also remains under consideration, following consultation on measures intended to improve transparency, reduce fraud and put UK reprocessors and exporters on a more even footing.
The FPA said the need for regulators to intervene to prevent enforcement action raises serious questions about how the system is managed and how future targets are set. It said it fully supports the drive to eliminate fraud and error, and that stronger accreditation, more rigorous verification and greater transparency are essential to confidence in the system. But, it added, if improving the integrity of recycling evidence exposes a substantial shortfall in availability, that should prompt a fundamental examination of the assumptions on which targets are based.
The association drew a distinction between relief from enforcement and resolving the underlying compliance problem, noting that statutory obligations remain unchanged and that producers meeting the reduced thresholds may still have non-compliance recorded against them. It argued that the review of 2027 targets must go beyond adjusting percentages and establish whether targets are backed by demonstrable domestic and overseas recycling capacity and reliable evidence supply, with assessments transparent and open to industry scrutiny.
It also said producers already face financial and administrative pressure from the wider packaging reform programme and should not be exposed to unpredictable compliance costs caused by a mismatch between obligations and the evidence market. The test of the government's response, it said, will be whether it delivers a more stable and achievable system for 2027 and beyond.